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CTA Files Comments on NHTSA Self-Driving Cars Proposal

Arlington, VA – November 22, 2016 –

In comments to the National Highway Traffic Safety Administration’s (NHTSA) proposed rules for self-driving cars, the Consumer Technology Association (CTA)™ welcomes the agency’s federal role in providing oversight and guidance to states, a smart approach in avoiding a patchwork of local laws that might impede the technology development process and unnecessarily delay the adoption of life-saving innovations. CTA’s comments support the aspects of the NHTSA policy that promote innovation and set clear, rational “rules of the road” for vehicle testing and development, including:

Clarification of the state and federal responsibilities with respect to automated vehicles;

NHTSA’s call for clear and consistent state laws and regulations that do not impinge on the agency’s authority with respect to vehicle safety and performance; and

NHTSA’s commitment to use its regulatory tools to facilitate the development, adoption and mass deployment of self-driving vehicles, as well as the agency’s proposal to expand its statutory exemption authority.

“Keeping pace with consumer expectations requires a balanced framework that recognizes the important roles that technology development plays in advancing safety,” said Gary Shapiro, president and CEO, CTA. “With the appropriate regulatory framework in place, and properly balanced between states and the federal government, we can dramatically reduce crashes caused by human error and eliminate 90 percent of traffic fatalities. We need uniformity across state lines and rules that keep pace with technological progress to make sure life-saving innovations can be tested and deployed quickly.”

However, CTA is most concerned about NHTSA’s suggestion of the possible introduction of pre-market approval for highly-automated vehicles. CTA also questions the application of NHTSA’s Vehicle Performance Guidance to “less-automated” vehicles (e.g., SAE levels L1-L2), as well the policy’s overbroad data sharing recommendations and discussion of possible post-sale authority to regulate software updates, among other provisions.

CTA’s comments highlight the transformative role that automated driving technologies can play in enhancing safety, increasing efficiency, expanding mobility and reducing costs. CTA research shows that U.S. consumers are eager to experience these benefits: 62 percent of U.S. consumers are interested in replacing their current cars or trucks with self-driving vehicles, and 70 percent have a strong interest in test driving one, according to the study CTA Self-Driving Vehicles: Consumer Sentiments.